This analysis describes what Betterment's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology
The clause is consequential because it confirms that personal information is disclosed to generative AI providers, while the only stated protection against training-data use is assurances received by Betterment rather than rights held by users.
The updated policy discloses a new Fully Paid Securities Lending program through Apex Clearing, under which Betterment will share customer personal information and account details with Apex if customers choose to participate. The revised terms also establish that generative AI service providers have committed that personal information will not be used for model training. For customers participating in promotional offers requiring offline fulfillment, the policy now explicitly states that personal information including mailing address may be shared with third-party partners. You can review the FPSL Program supplemental disclosures for details about the securities lending arrangement, or choose not to participate in the program.
View change record →Users' personal information is shared with generative AI providers; the protection against its use for model training rests on assurances those providers give to Betterment.
How other platforms handle this
Your personal information may be transferred to countries other than where you live, such as, for example, to our servers in the US.
if you are accessing and using Lime Services under a corporate account...you acknowledge and agree that Lime may share certain of your usage information with whomever provided you with access to the Lime Services
We will disclose personal information to companies that help us run our business to detect, prevent, or otherwise address fraud, deception, illegal activity, misuse of Adobe Services and Software, and security or technical issues.
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Betterment has changed this document before.
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"These service providers also include providers of generative artificial intelligence technologies (including large language models), from which we receive assurances that your personal information is not used for the purpose of model training.— Excerpt from Betterment's Betterment Privacy Policy
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The clause is consequential because it confirms that personal information is disclosed to generative AI providers, while the only stated protection against training-data use is assurances received by Betterment rather than rights held by users.
Users' personal information is shared with generative AI providers; the protection against its use for model training rests on assurances those providers give to Betterment.
ConductAtlas has identified this type of provision across 289 platforms. See the full comparison.
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